At
the
request and on the behalf of TriMas Corporation (the “Company”), please find
below the Company’s proposed response to comment number 9 of the SEC comment
letter dated April 24, 2007. Following your review of this
information, the Company will be happy to discuss any further questions you
may
have. In the interim, feel free to contact
me
at (212) 701-3036 with any questions you may have.
Note
16 – Employee Benefit Plans
|
9.
|
You
indicate in Note 3 that you will adopt SFAS 158 in
2007. However, it appears that paragraphs 11(b) and 12 require
that you adopt the requirement to recognize the funded status of
your
benefit plans and the disclosure requirements of SFAS 158 in your
fiscal
year ended December 31, 2006. Please revise or
advise.
|
We
acknowledge the provisions of paragraph 11(b) would require us to adopt the
requirement to recognize the funded status of our benefit plans and the
disclosure requirements of SFAS 158 in our financial statements for the year
ended December 31, 2006. In considering the need to amend our
previously issued financial statements, we considered the materiality of the
impact of not recognizing the funded status of our benefit plans in our
financial statements for the year ended December 31, 2006. While, we
believe the impact of not recognizing the funded status of our benefit plans
in
our financial statements for the year ended December 31, 2006 is not material,
we intend to recognize the impact in the financial statements for the quarter
ended March 31, 2007.
Materiality
Considerations
With
respect to the Company’s pension plans, the impact of recognizing the funded
status in our balance sheet would be to increase the accrual for pension
liabilities in the amount of $1,765,000. With respect to the
Company’s post-retirement benefit plans, the impact of recognizing the funded
status in our balance sheet would be to increase the accrual for post-retirement
benefit liabilities in the amount of $1,800,000. The combined
increase to accrued liabilities of $3,565,000 represents approximately 0.34%
of
the Company’s total liabilities. The impact of recording this
additional liability would be to decrease Accumulated Other Comprehensive Income
in the amount of $2,210,000, or 0.95% of the Company’s
reported
shareholder’s equity and increase deferred tax assets in the amount of
$1,355,000, or 0.43% of total current assets reported. Further, there
would be no impact to the Company’s cash flows as reported and there will be no
impact to the Company’s 2007 statement of operations as a result of not
recognizing the funded status of our benefit plans in the financial statements
as of December 31, 2006.
/s/
Douglas S. Horowitz
Douglas
S. Horowitz
Mail
Stop
0404
Securities
and Exchange Commission
450
Fifth
Street, N.W.
Washington,
D.C. 20549-0404
VIA
EDGAR
|
cc:
|
Rufus
Decker
Brigitte
Lippmann
Lesli
Sheppard
Grant
Beard
E.R.
Autry, Jr.
Joshua
Sherbin
Bob
Zalupski
Doug
Horowitz
Jason
Terrana
Brian
Kleinhaus
|
-2-